INTRODUCTION

In accordance with transparency obligations of the the EU Regulation 2016/679 General Data Protection Regulation (hereafter the “GDPR”), this Privacy Notice (hereafter “the Notice”) explains how the University of Luxembourg processes and protects your Personal Data in relation with your status as Alumni.

     1) WHO ARE WE?

The University of Luxembourg is a public higher education and research establishment, operating under the supervision of the Ministry for higher education.

The University of Luxembourg has its official address at:

MAISON DU SAVOIR
2, avenue de l’Université
L- 4365 ESCH-BELVAL

Phone number: Tel.: (+352) 46 66 44 1

Internet address: https://www.uni.lu/en/

The University has appointed a DPO reachable during working hours. Further information is provided on https://www.uni.lu/en/about/organisation/administration/data-protection/ and an email address is available: dpo@uni.lu

     2) WHY DOES THE UNIVERSITY PROCESS YOUR PERSONAL DATA?

Alumni Relations & internal services of the University e.g Office of Statistics, Research Support Department aims to stay in contact with our alumni after they leave the University in order to provide alumni-specific services, invitations to events, send newsletters, propose surveys, liaise for career development in the context of National or European Funding and to engage with them for support and feedback on the University’s ongoing development. The University decided to offer an Alumni platform to you that is hosted by the company Eudonet which is located in Paris, FRANCE.

     3) WHICH PERSONAL DATA DO WE COLLECT AND FURTHER PROCESS?

The categories of personal data processed are detailed below:

   - In addition to your academic data from your time as students, doctoral candidates in the context of their enrolment at the University and their study cursus stored in accordance with the legal prescriptions, current personal and professional contact information and publicly available information from social media and professional networks, e.g personal data published on Linkedin, ResearchGate such as profile URL, employer, job title, location of the employer.

   - Contact details such as private email addresses, first name, last name, your answers to an online survey questionnaire including questions about the sector of employment, the current job position, the minimum education requirement for the current position, the reasons for taking the current position, job satisfaction, the duration of possible unemployment periods, future career plans as well as the efficiency of the University’s career development offer and scientific and transferable skills training. Questions that are not marked as mandatory may be skipped.

     4) HOW DOES THE UNIVERSITY PROCESS PERSONAL DATA?

The University Luxembourg processes the Personal Data directly from you when you enrolled as a student and doctoral candidate and from your relationship with the Alumni Officer and other persons at the University who handle Alumni Relations. They are also processed by internal services detailed in section 2. We collect and process indirectly personal data which you make publicly available on social media and professional networks about your professional background and career in order to better know you and provide you the appropriate services.

     5) ON WHICH LEGAL BASIS DOES THE UNIVERSITY PROCESS YOUR PERSONAL DATA?

The legal basis for the processing of your personal data for Alumni purposes as described in section 3 is the legitimate interest of the University in accordance with article 6.1 f) GDPR as that is a common interest when you become Alumni to be able to take advantage of the Alumni services, be able to provide information about your further career development when your position is funded by the FNR or European Commission and that it is the interest of the University to develop and handle Alumni services as a University. Furthermore it is necessary for the performance of the legitimate interest of the University of Luxembourg to have at its disposal the information required to improve its services and be able to adapt them to the needs of its students.

     6) WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?

Employees of the University of Luxembourg engaged in Alumni relations such as members of the Alumni relations department (including Alumni Officer) and members of the Alumni Committee (e.g administrators of the alumni platform), members of the Office of Statistics, members of the Research Support Department . For offers to alumni from external organizations, the University may be obliged to confirm your eligibility for said offers with these organizations, although only upon request of these organisations and only by confirming your status as Alumni.

On the alumni platform, users may choose to make their profiles visible to external recruiters who would then have access to information such as their CV and professional information provided on their profiles.

Eudonet is the processor of the University in order to offer several services on the Alumni platform such as to maintain and update a directory of graduates, to allow the organisation of events, to make job offers available to alumni. The University and Eudonet concluded an agreement and a data processing agreement in accordance with the GDPR. Eudonet employees dedicated to the services provided to the University have access to your data. Security measures have been implemented to ensure the confidentiality of your data.

For PHD Career development in the context of PRIDE, the data collected with the survey will be shared internally with different services in central administration. In case of affiliation to an FNR PRIDE-funded DTU, the data may be shared with the DTU coordinator(s) and supervisors in all the partner institutions (e.g. University of Luxembourg, Laboratoire National de Santé). It will also have to be transferred to the FNR six (6) years after the end of the PRIDE programme as requested in article 6.6 the PRIDE Convention.

     7) DOES THE UNIVERSITY TRANSFER YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN UNION?

Your Personal Data is mainly processed within the European Union for the different purposes listed in section 2. If future Alumni Clubs are established outside the European Union, any transfer of your contact details will only take place if you are informed and your express informed consent will be required in accordance with article 49 GDPR. In any cases whether the University will transfer your personal data in the context of your participation in a Survey or in relation to the status of your Career Development under the FNR- PRIDE funding instrument, appropriate safeguards will be implemented in accordance with article 45 & 46 of the GDPR or appropriate derogations will be implemented in accordance with art.49 GDPR.

     8) HOW LONG DOES THE UNIVERSITY STORE YOUR PERSONAL DATA?

The retention period will depend on the purposes.

For Alumni service purposes, the Personal Data provided by you are kept as long as the Alumni wish to remain in contact with the University. If you do not want to be contacted as Alumni you can unsubscribe from any services by sending an email to alumni@uni.lu or in your profile settings on the alumni platform.

The same retention period applies for the participation to the Surveys. We keep your contact details as soon as you agree to be contacted and if you do not want to participate anymore to Surveys you can send an email to osir@uni.lu.

For PHD Career development related to PRIDE; your data will be retained for a period of ten years following the start of your PhD work contract. Afterwards, only representations of pooled survey data (plots, tables) that do not allow the identification of the individual survey responder will be kept.

     9) WHAT ARE YOUR RIGHTS WITH REGARD TO THE PROCESSING OF YOUR PERSONAL DATA?

According to the GDPR, you benefit notably from the following rights: right to be informed, right to access to your personal data, right to rectification, right to erasure, right to restrict the scope of the processing, right to object, right to data portability, right to lodge a complaint. The University provides further information on its website page: https://www.uni.lu/en/about/organisation/administration/data- protection/your-rights/.

In practice, you can exercise your rights by contacting the Alumni Officer at alumni@uni.lu or the Data Protection Officer at dpo@uni.lu. The DPO can also be contacted per post to

Université du Luxembourg À l’attention de: DPO – Exercise of Data Subject rights
Maison du Savoir
2, Avenue de l’Université
L-4365 ESCH BELVAL

Any request shall be processed by the University of Luxembourg without undue delay, and where feasible no later than one (1) month after its receipt, at least in order to inform you about the status of your request. This period may be extended for two (2) additional months for complex cases or due to a high volume of requests.

     10) HOW CAN YOU LODGE A COMPLAINT?

If you consider that the Processing of Personal Data relating to you infringes on the GDPR, you have the right – without prejudice to any other administrative or judicial remedy – to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.

In Luxembourg, the competent authority is the Commission Nationale pour la Protection des Données (CNPD).

Contact of the CNPD:
Commission Nationale pour la Protection des Données 1, avenue du Rock’n’Roll
Service des réclamations
L-4361 Esch-sur-Alzette
Tel. : (+352) 26 10 60 -1
Fax : (+352) 26 10 60 -29

You can also use their contact form at: https://cnpd.public.lu/fr/support/contact.html

     11) APPLICABLE LAW – JURISDICTION

The present Notice shall be governed and construed in accordance with Luxembourgish law.
Any dispute concerning the existence, interpretation or performance of this Notice which cannot be settled amicably, shall fall within the jurisdiction of the Courts of Luxembourg City, without prejudice to the rights of the Data Subjects to bring the matters before the court where he or she has her place of residence as well as its right to lodge a complaint with the supervisory authority.